Inc., 531 F.3d 127, 135 (2d Cir. 2008); Shine v. N.Y.C. Housing Auth., No. 19-CV-4347 (RA), 2020 WL 5604048, at *3 (S.D.N.Y. Sept. 18, 2020) (stating the elements required for a Rehabilitation Act claim). “What matters under the ADA are not formalisms about the manner of the request, but whether the employee . . . provides the employer with enough information that, under the circumstances, the employer can be fairly said to know of both the disability and desire for an accommodation.” Goonan v. Fed. Rsrv. Bank of N.Y., No. 12-CV-3859 (JPO), 2014 WL 3610990, at *5 (S.D.N.Y. July 22, 2014) (quoting Taylor v. Phoenixville Sch. Dist., 174 F.3d 142, 162, on reh'g, 184 F.3d 296 (3d Cir. 1999)); see, e.g., Malzberg v. New York Univ., No. 19-CV-10048 (LJL), 2022 WL 889240, at *13 (S.D.N.Y. Mar. 25, 2022) (notice satisfied where an individual applied to another position and showed up to work); Kurlender v. Ironside Grp. Inc., No. 18-CV-3839, 2019 WL 1317405, at *3 (E.D.N.Y. Mar. 22, 2019) (notice pled where plaintiff discussed with employer changing travel plans for “health reasons” and sent employer a form marking the box for “disabled”).

Adequate notice does turn on if “the employee or a representative for the employee provides the employer with enough information that, under the circumstances, the employer can be fairly said to know of both the disability and desire for an accommodation.” Kurlender v. Ironside Grp., Inc., 18-CV-3839 (JFB) (AYS), 2019 WL 1317405, at *3 (E.D.N.Y. Mar. 22, 2019) (citation omitted)).

19, 2020) (same); Kurlender v. Ironside Grp., Inc., 2019 WL 1317405, at *3 (E.D.N.Y. Mar. 22, 2019) (same);

The question of whether an employer has adequate notice of an employee's claimed disability does not turn on the form in which the notice was given (i.e., oral or written), or on whether the notice was given to the employer's HR department (as opposed to the employee's supervisors), or on whether the notice was accompanied by medical support. See Kurlender v. Ironside Grp., Inc., No. 18-CV-3839 (JFB) (AYS), 2019 WL 1317405, at *3 (E.D.N.Y. Mar. 22, 2019) (“What matters under the ADA are not formalisms about the manner of the request, but whether the employee or a representative for the employee provides the employer with enough information that, under the circumstances, the employer can be fairly said to know of both the disability and desire for an accommodation.” (citation omitted)).

In this case, the combination of Eckhart's positive performance record and feedback continuing right up to her February 2020 complaint to Hirst and Collins, see Compl. ¶¶ 30, 33, as well as the proximity of her alleged protected activity to her termination, supports an inference of a causal connection. See Kurlender v. Ironside Grp., Inc., 18-CV-3839 (JFB), 2019 WL 1317405, at *5 (E.D.N.Y. Mar. 22, 2019) (“Given plaintiff's detailed allegations that he was terminated from his position for supposed ‘poor performance,' yet he had not received any ratings or evaluations as to performance, and had even been assured ‘that his performance was superior and that he was doing a great job,' in conjunction with the temporal proximity [of six or seven months] between plaintiff's protected activity and his termination, the Court concludes that plaintiff has plausibly stated a claim for retaliatory termination.”

Under the ADA, determining whether a plaintiff sought a reasonable accommodation is not concerned about "formalisms about the manner of the request, but whether the employee . . . provides the employer with enough information that, under the circumstances, the employer can be fairly said to know of both the disability and desire for an accommodation." Kurlender v. Ironside Grp., Inc., No. 18-CV-3839, 2019 WL 1317405, at *3 (E.D.N.Y. Mar. 22, 2019) (quoting Taylor v. Phoenixville Sch. Dist., 184 F.3d 296, 313 (3d Cir. 1999)); see also Quadir v. New York State Dep't of Labor, 39 F. Supp. 3d 528, 540 (S.D.N.Y. 2014) (same); Goonan v. Fed. Reserve Bank of New York, No. 12-CV-3859, 2014 WL 3610990, at *5 (S.D.N.Y. July 22, 2014) (same). The Court concluded previously that Plaintiff pled facts sufficient to suggest that Bryant perceived Plaintiff as disabled.

"What matters under the ADA are not formalisms about the manner of the request, but whether the employee ... provides the employer with enough information that, under the circumstances, the employer can be fairly said to know of both the disability and desire for an accommodation." Goonan , 2014 WL 3610990, at *5 (on motion to dismiss); see alsoDipinto v. Westchester Cnty. , 2020 WL 6135902, at *6 (S.D. N.Y. Oct. 19, 2020) (same); Kurlender v. Ironside Grp., Inc. , 2019 WL 1317405, at *3 (E.D. N.Y. Mar. 22, 2019) (same); Quadir v. New York State Dep't of Lab. , 39 F. Supp. 3d 528, 540 (S.D. N.Y. 2014) (same). ( 2022 WL 889240, at *14 [S.D.N.Y. 2022 [emphasis added] ).